After hearing a motion at the close of the evidence, I have
determined that the plaintiff has failed to present the proof that the law
requires to prevail on ((his/her) claim / some of (his/her) claims, namely,
____________________). Since I have made this legal determination, I am
directing you that the law requires that you render a verdict in favor of the
defendant [on count[s] ____].

The verdict form which you will use for this purpose is
headed "Defendant's Verdict." <Describe finding for defendant on particular
counts on the verdict form>. You should elect a foreperson, who should sign
this verdict form on behalf of the jury at the direction of the court.